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MemoMemorandumObama · D Quiet signal

Presidential Memorandum

Delegation of Certain Functions and Authorities Under Section 213(b)(1) of the Iran Threat Reduction and Syria Human Rights Act of 2012

This memorandum delegates presidential authority under Section 213(b)(1) of the Iran Threat Reduction and Syria Human Rights Act of 2012 from the Secretary of the Treasury to the Secretary of State, requiring consultation with multiple other cabinet members and agency heads. It rescinds the 2012 delegation to Treasury while leaving other provisions of that earlier memorandum intact.

Federal Register Open PDF 80 FR 66781

Impact dates

  1. Secretary of State to publish memorandum in Federal Register

Key directives

  • Delegate TRA Section 213(b)(1) authority to Secretary of State
  • Require consultation with Treasury, Commerce, USTR, DHS, Federal Reserve, and other agencies
  • Rescind 2012 delegation of same authority to Secretary of Treasury
  • Preserve other provisions of 2012 memorandum
  • Secretary of State to publish in Federal Register

Who is ordered

Timeline

Immediate

  • Delegation to Secretary of State takes effect
  • Prior delegation to Treasury rescinded

Near term (90d)

  • Secretary of State to publish memorandum in Federal Register

Long term

  • Ongoing sanctions authority exercised by State Department rather than Treasury

Risks & tensions

  • Interagency coordination burden with 5+ required consultees may slow decision-making
  • Shift from Treasury to State may reflect differing institutional priorities on sanctions enforcement
  • Rescission without full revocation of 2012 memo creates potential ambiguity about which provisions remain
Presidential Memorandum: Delegation of Certain Functions and Authorities Under Section 213(b)(1) of the Iran Threat Reduction and Syria Human Rights Act of 2012 · Executive Orders